Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Procedures for bank guarantees and customs bonds under Indian customs law, detailing obligations for importers/exporters (obligors) and banks. Key provisions include: The bank guarantee framework requires banks to undertake payment to the government up to a specified amount in case of breach by obligors. Banks must provide unconditional guarantees without demur upon government demand, with liability restricted to the guaranteed amount. The guarantee remains effective until obligations are fulfilled and certified by relevant authorities. Banks cannot revoke guarantees during currency without prior government consent. Electronic transmission through SFMS (Structured Financial Messaging System) is mandatory for operationalizing paper bank guarantees, with specific message formats and field requirements. Non-compliance with SFMS procedures may prevent guarantee confirmation and subsequent processing.
Procedures for bank guarantees and customs bonds under Indian customs law, detailing obligations for importers/exporters (obligors) and banks. Key provisions include: The bank guarantee framework requires banks to undertake payment to the government up to a specified amount in case of breach by obligors. Banks must provide unconditional guarantees without demur upon government demand, with liability restricted to the guaranteed amount. The guarantee remains effective until obligations are fulfilled and certified by relevant authorities. Banks cannot revoke guarantees during currency without prior government consent. Electronic transmission through SFMS (Structured Financial Messaging System) is mandatory for operationalizing paper bank guarantees, with specific message formats and field requirements. Non-compliance with SFMS procedures may prevent guarantee confirmation and subsequent processing.
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